Mail Stop 4561
									October 24, 2005

Mr. Angelo Napolitano
President and Chief Executive Officer
Miller Industries, Inc.
16295 N.W. 13th Avenue
Miami, FL 33169

      Re:	Miller Industries, Inc
		Form 10-KSB for Fiscal Year Ended April 30, 2005
		Filed September 19, 2005
		File No. 1-05926

Dear Mr. Napolitano:

      We have reviewed your filing and have the following
comments.
We have limited our review to only your financial statements and
related disclosures and do not intend to expand our review to
other
portions of your document.  Where indicated, we think you should
revise your document in response to these comments.  If you
disagree,
we will consider your explanation as to why our comment is
inapplicable or a revision is unnecessary.  Please be as detailed
as
necessary in your explanation.  In some of our comments, we may
ask
you to provide us with information so we may better understand
your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Form 10-KSB for the Fiscal Year Ended April 30, 2005

Item 8A. Controls and Procedures, page 9
1. We note your statement that your chief executive officer and
your
chief financial officer "concluded that the Company`s disclosure
controls and procedures were adequate."  It does not appear that
your
certifying officers have reached a conclusion that your disclosure
controls and procedures are effective.  Please revise to address
your
officers` conclusions regarding the effectiveness of your
disclosure
controls and procedures.

2. Please revise to disclose changes in internal control over
financial reporting pursuant to Item 308(c) of Regulation S-B.

Item 13. Exhibits, Financial Statement Schedules and Reports on
Form
10-KSB, page 13

3. Please revise your certification filed as exhibit 31.1 to
reflect
the language exactly as set forth in Item 601(b)(31) of Regulation
S-
B.  Refer to Management`s Report on Internal Control over
Financial
Reporting and Certification of Disclosure in Exchange Act Periodic
Reports, SEC Release No. 33-8238, available on our website at
 for guidance.

Note C - Income Taxes, page 25

4. Please explain to us how you evaluated the various factors
addressed in paragraphs 20 through 25 of SFAS No. 109 when
determining that only $76,000 and $44,000 of your deferred tax
asset
is more likely than not to be realized as of April 30, 2005 and
2004,
respectively.  We note from review of this document and previous
filings that you have generated positive earnings in each of the
past
five years.

Form 10-QSB for the Fiscal Quarter Ended July 31, 2005

5. Please tell us when you intend to file your Form 10-QSB for the
fiscal quarter ended July 31, 2005, which was due on September 14,
2005.

      As appropriate, please amend your filing and respond to
these
comments within 10 business days or tell us when you will provide
us
with a response.  You may wish to provide us with marked copies of
the amendment to expedite our review.  Please furnish a cover
letter
with your amendment that keys your responses to our comments and
provides any requested information.  Detailed cover letters
greatly
facilitate our review.  Please file your cover letter on EDGAR.
Please understand that we may have additional comments after
reviewing your amendment and responses to our comments.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that:


* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and

* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Amanda Sledge, Staff Accountant, at (202)
551-
3473 or the undersigned at (202) 551-3403 if you have questions.



								Sincerely,



      Steven Jacobs
      Accounting Branch Chief
Mr. Angelo Napolitano
Miller Industries, Inc.
October 24, 2005
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